14. Any other comments or suggestions

Question 14: Any other comments, suggestions.

14.1 The final consultation question invited any further
comments or suggestions. Many respondents took the opportunity to
reiterate their main points already made in relation to previous
questions. Some provided background information on their
organisation. Several described how they had consulted across their
organisation in preparing their response, demonstrating a wide
engagement over and above the 499 responses submitted.

14.2 Amongst the responses to the full consultation and the
easy-read version, emerged a number of broad themes, outlined
below.

Support for the Standards

14.3 There was considerable support for the Standards as drafted
and an appreciation of what was viewed as the thorough and
thoughtful development work which had led to this stage.

14.4 The Standards were perceived to be a potential tool for
partnership working, underpinned by a shared understanding between
partners of expectations of provision. They were seen as helping to
highlight where services need to join and work together for the
benefit of service users. One respondent commented that the
Standards provided a reference point for continual improvement.

Views on further refinements

14.5 The Standards were viewed by some respondents as requiring
further editing to make them shorter and more streamlined. They
were perceived to be overwhelming in detail in places, which some
felt was off-putting.

14.6 A small number of respondents considered that some of the
statements could appear patronising; one respondent suggested that
the text be proofed for potentially discriminatory language.

14.7 A few respondents highlighted what they perceived to be
inconsistencies in the Standards. These included:

Broad statements along with relatively prescriptive
statements.

Mix of "hard" and "soft" aims.

Focus alternating between outcomes and processes.

"Jargonise" mixed with "easy-read" text.

Lengthy statements mixed with concise, short statements.

Mix of what were perceived to be minimum Standards with
aspirational Standards.

Word "care" used inconsistently, sometimes with "health",
sometimes with "social" and sometimes by itself.

14.8 Respondents emphasised the need for definitions in the
Standards to be consistent with those used in related contexts,
with the term "early years" highlighted most frequently in this
regard. Suggestions were made for the glossary to include
definitions of "person-centred", "wellbeing", "transitions" and
"compassion".

Views on linking with broader contexts

14.9 A few respondents emphasised the need for the Standards to
acknowledge broader, related contexts which may have their own
regulator and prioritites. An example was provided of pharmacists
who have their own new Standards and a different regulator.

14.10 One respondent highlighted the need for those working in
related areas to recognise that the new Standards are relevant to
them. The example given was forensic medical examinations for
victims of sexual assault which may be done in police or other
multi-agency premises, and at which healthcare professionals and
others must recognise that the Standards are applicable.

14.11 Many respondents identified related guidance and
legislation which they considered should be referenced explicitly
in the Standards: Excellence in Care; Quality of Care Reviews;
Quality Assurance programmes; health and safety legislation and
risks; Carers (Scotland) Act to be implemented in 2018; Patient
Rights (Scotland) Act 2011; and the current review of health and
social care targets and indicators.

14.12 A recurring theme was that implementing the Standards
should be assessed against the backcloth of limited resourcing and
different financial priorities across different regions.

Views on balances and tensions

14.13 There were contrasting views on the universal approach
adopted by the Standards. Whilst a few respondents welcomed this as
simple and comprehensive, others considered that this was too
broad-brush and masked the complexities of the "diverse landscape"
of health and social care provision.

14.14 Several respondents remarked on the balance of focus on
health care and social care in the Standards, with a recurring view
that they appear weighted towards social care. A few respondents
suggested that the Standards should be aligned with the Health and
Social Care Delivery Plan (Dec 2016).

14.15 Views emerging from a few of the engagement events were
that there may be some conflict of interest between professional
guidance and the Standards. The example of infection control vs
child protection was given. Questions were raised over how the
Standards would fit with various Codes of Practice.

14.16 One respondent considered that the Standards were a mix of
Guidelines and Standards, and sought clarity on this.

Incapacity issues

14.17 The person-centred approach, and in particular the
drafting of the Standards in the first person, led a few
respondents to suggest that a key gap in the Standards is reference
to supported decision-making for people with dementia, incapacity,
and those with learning disabilities.

14.18 A related issue was raised by one respondent from the
voluntary sector, who suggested that gathering evidence to
demonstrate compliance with the Standards may be affected by
individuals' capacity and the various safeguarding issues that
surround them.

Moving forward

14.19 A common view was that the Standards are generally
applicable, but will need to be implemented in a meaningful and
systematic way to ensure effectiveness. Effective implementation
was viewed as including high quality commissioning, high quality
monitoring of provision, and robust inspection approaches.

14.20 Several respondents raised issues of future inspection of
services and provision, with recurring views being that inspectors
will need to update their training and methods to accommodate the
new Standards and their universal approach; there will need to be a
process for agreeing which Standards are relevant to which service;
and some Standards will need further description to make them
measurable.

14.21 Many respondents emphasised the need for thorough
preparation before the launch of the new Standards. The challenges
ahead were acknowledged with requests made for an adequate lead-in
period and robust implementation strategy.

14.22 A recurring view was that the Standards need to be
accessible and "portable". Different formats were envisaged to
enable inclusive access, along with the development of appropriate
educational resources to underpin and support implementation.